Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57480

Received: 10/12/2021

Respondent: Defence Infrastructure Organisation

Representation Summary:

Barton Road Riffle Range is a core defence facility that is proposed to fall within a strategic Green Infrastructure area. The range does not fall within the definition of Green Infrastructure. Designating the site as GI would introduce constraints and potential incompatible uses that could place unreasonable restrictions on how the MOD currently and in the future use the land. We would strongly recommend that the proposed boundary is amended to avoid the MOD ownership and that any GI boundary ensures GI compatible uses are sufficiently located so as not to constrain defence operations now or in the future.

Full text:

The policy seeks to identify the existing Green Infrastructure (GI) network and the strategic initiative intended to enhance it. It defines Green Infrastructure as the network of green spaces and routes, landscapes, biodiversity, water bodies and heritage which provide a range of benefits for people wildlife and the planet. It seeks to define 14 area-specific dispersed long term priority enhancements to the GI network – described as strategic initiatives that will include providing green space for people to enjoy. Strategic initiative 7 defines the West Cambridge green infrastructure buffer – Coton Corridor. This area is shown in figure 54 of the Great Cambridge Local Plan First Proposals, within which is a substantial Ministry of Defence Land holding which includes Barton Road Rifle Range. Barton Road Rifle range is a core defence facility, being only 1 of 3 ranges in the country where long distance practice firing can take place. It is extensively used for both sniper training and pre-deployment training. The MOD holdings extend outside of the operational range area and are held for operational defence purposes.

The NPPF at paragraph 92 explains that planning policies should aim to achieve healthy, inclusive and safe places which include the provision of safe and accessible (my emphasis) green infrastructure. The NPPF defines GI as a network of multi-functional green and blue spaces. The rifle range by its very nature is not a multi-functional green space and holds a very specific single purpose for the essential training of military personnel. The nature of military activities means the land is enclosed and public access is not permitted. Accordingly, the range is neither safe nor accessible to fall within the definition or functional purpose of GI.

It is important to recognise that the landholdings are required for the purpose of national defence and the planning process serves to protect such national infrastructure (as per paragraph 97 of the National Planning Policy Framework). The MOD’s land holding would not provide public recreation or multi-functional use to be considered GI. In addition, the proposed boundary to this designation does not follow easily identifiable and physical features on the ground for the boundaries of GI to be permanent and to endure throughout and beyond the plan period. For assistance a copy of the MOD ownership boundary has been included.

In accordance with paragraph 97 of the NPPF planning policies should promote public safety and defence requirements. It is fundamental that policies within the new local plan do not affect adversely the operation of this key training facility. Designating the site as GI would introduce constraints and potential incompatible uses that could place unreasonable restrictions on how the MOD currently and in the future use the land. We would strongly recommend that the proposed boundary is amended to avoid any of the MOD ownership and that any GI boundary ensures GI compatible uses are sufficiently located so as not to constrain defence operations now or in the future.

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